Memorandum submitted by Promo Veritas
PROMOTIONAL COMPLIANCE
MADE EASY
We note that the Culture, Media and Sport Committee
will be holding hearings into Call TV in November. We are pleased
to supply what we hope is some relevant information for them:
Background:
PromoVeritas are specialists in promotional
verification. We seek to ensure the compliance of promoter's activities
to the law and the Codes of practice and so enhance their reputations
in the eyes of the consumer and the trade.
For competitions we act as independent judges,
selecting the winners on the basis of agreed criteria.
For prize draws we randomly and without bias
select the winners
For instant wins we ensure that there are the
appropriate number of prizes, that they are security marked and
manually and randomly seeded into the production runs. In addition
we supervise No Purchase Necessary routes that are used by promoters
to avoid issued under the Lotteries Act and generally advise them
on terms and conditions and fairness.
Our mainstream clients include Coca-Cola, Budweiser,
McVities, Unilever and ASDA.
So we are the one's who have picked the winners
of the Coca-Cola Win A Player promotion, the Ribena Win a Donkey
promotion and the Budweiser Grand Prix World Trip Tickets.
GOOD PRACTICE
IN THE
INDUSTRY
In mid 2005 we got involved with the Call TV
industry and now verify all of the output of The Great Big British
Quiz channel which has outputs on Sky and also late night channel
5.
Our work for the channel included an end to
end review of their internal process, from how and who prepared
the rules for puzzles, created the puzzles issued the puzzles
and how the answers were announced on the show.
The aim was to reduce the risk of internal abuse,
inaccuracy and unfairness in the setting of the puzzles. We have
now established the following protocols
— Rules for any new proposed puzzle
type are now approved by us in advance;
— All puzzles, from agreed rules, are
sent to us for checking before broadcast;
— All approved puzzles are uniquely
coded and kept securely in a password area until required;
— Presenters have been given guidelines
on what to say and what not to say for each puzzle type;
— All answers are securely kept in
an "answer Checker" PC in the Production Area to which
only two people have access. Answers submitted by the public are
entered by an operator and only if there is a match is the answer
revealed.
— There is now an effective complaint
handling process; and
— The No Purchase Necessary route provides
an equal chance of entry.
This last point is of special note: despite
the high level of skill and judgement required to answer many
of these puzzles, they would still run the risk of falling foul
of Lottery regulations because of the randomness of the entry
process—phone up and only a small% are ever put on air.
For this reason, we also validate the randomness
of the No Purchase Necessary route. that is available via the
internet and is the chosen route for many entrants, as well as
being the "get out" of problems with the Lottery act.
Finally we also conduct random checks on the
back end including the paying out of the stated prizes to the
stated winners.
Our name, PromoVeritas Ltd, is used on the website'and
on screen graphics as an indication that the channel is operating
fairly and above board. As a result we do receive a number of
consumer complaints—directly and indirectly- but in the
majority of cases, once the complainant is made aware of our presence
and our processes they are happy with the situation.
Despite being paid for by the channel, our role
is still to challenge them as appropriate, and we have rejected
many new types of puzzles or adjusted',the rules to ensure consistency,
believability and fairness.
As a result of the introduction of the above
processes; and making them known to both staff and viewers, the
channel has reduced its level of complaints, expanded its business
and avoided a single incidence of internal malpractice.
We therefore believe that even within the current
legislative framework it is possible to provide the necessary
integrity and independence, via the use of a third party service
such as ours.
November 2006
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